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U.S. Income Tax Compliance

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Form 5471<br />

• Penalties<br />

– Any person who fails to file or report all of the<br />

information requested on Schedule O is<br />

subject to a $10,000 penalty for each such<br />

failure for each reportable transaction.<br />

• If the failure continues 90 days or more after the<br />

IRS has mailed a notice of the failure to the U.S.<br />

person, an additional $10,000 penalty will apply for<br />

each 30-day period, or fraction thereof, during<br />

which the failure continues after the 90 day period<br />

has expired up to a maximum of an additional<br />

$50,000 penalty.

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